Taxation of Artistes and Sportsmen in International Tax Law

S. 483Value-Added Taxation and Contract-Splitting in relation to International Artistes and Sportsmen

Kooiyang Cheah

S. 485I. Introduction

International artistes and sportsmen are seen as mega-rich and highly mobile people, largely due to the highly visible nature of their work, as well as their seemingly extravagant income and lifestyles. However, the fact that international artistes and sportsmen are highly visible is hardly their fault – their livelihood depends on them being visible. Nevertheless, international artistes and sportsmen seem to be special targets of taxation authorities world-wide. Incredibly, some countries even have special tax-laws to govern the taxation of international artistes and sportsmen. The Sixth Directive is no exception. Thus, efforts must be taken by an international artiste or sportsman to avoid, or at least minimise the risk associated with such tax-laws that may result, whether justly or unjustly, direct or indirectly, in a substantial reduction in the international artiste’s or sportsman’s net total disposable income.

Only issues related to international artistes and sportsmen in the provision of services would be addressed in this ...